Comments to the CESR on the MiFID Level 3 Work Plan

SIFMA, the Alternative Investment Management Association, the Association of Foreign Banks, the Association of Private Client Investment Managers and Stockbrokers, the European Association of Securities Dealers, the British Bankers’ Association, the Bundesverband der Wertpapierfirmen an den deutschen Börsen, the Danish Securities Dealers Association, the Euribor ACI European Commission Working Group, the Finnish Association of Securities Dealers, the Futures and Options Association, the Icelandic Financial Services Association, the International Capital Market Association, the International Swaps and Derivatives Association, and the Norwegian Securities Dealers Association provide comments to the Committee of European Securities Regulators (CESR) on the The Markets in Financial Instruments Directive (MiFID) Level 3 Work Plan.  In particular, SIFMA, et al, are discussing the Question and Answer (Q&A) section, with concerns about the status of the Q&A, editorial control of the Q&A, the process for generating answers, and the relationship between CESR’s Q&A and the Commission’s Q&A.